Lane v The QueenCitation:[2018] HCA 28Before:Kiefel CJ, Bell, Gageler, Keane, Edelman JJDate:20 Jun 2018Case Number:S308/2017Read more

Lane v The QueenCitation:[2018] HCA 28Before:Kiefel CJ, Bell, Gageler, Keane, Edelman JJDate:20 Jun 2018Case Number:S308/2017Read more

The absence of a unanimity direction was an error, but the court found that no substantial miscarriage of justice had actually occurred, permitting the application of the proviso.

Parties
Appellant: Unknown (Appellant); Respondent: Unknown (Respondent)
Jurisdiction
Australia
Judgment Date
20 June 2018
Procedural Posture
Criminal Appeal / Judgment
Outcome
appeal dismissed
Legal Topics
Appeal Against Conviction, Application of Proviso, Jury Directions, Unanimity Requirement, Manslaughter

Case Brief

Summary, issues, holding and outcome

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Parties

Unknown (Appellant)

Appellant

Unknown (Respondent)

Respondent

Procedural Posture

Criminal Appeal / Judgment

  1. 1 Whether the absence of a unanimity direction to the jury constituted a substantial miscarriage of justice
  2. 2 Whether the proviso could be applied despite the trial judge's error in failing to direct the jury as to unanimity on the specific act causing death

Ratio Decidendi

The absence of a unanimity direction was an error, but the court found that no substantial miscarriage of justice had actually occurred, permitting the application of the proviso.

Court Disposition

appeal dismissed

Orders

  • Conviction upheld
  • No order as to costs